Casino Control Act 1991

The Act casts a wide net across operators, employees, regulators, patrons, and ancillary parties.

Casino operators (defined in s.3(1) as holders of a casino licence under Part 2) bear primary obligations. They must implement approved internal controls (s.121), comply with directions (s.23), notify significant breaches (s.27A), maintain independent boards and management (Part 3A), and pay supervision charges (s.112B). The Melbourne Casino Operator faces additional scrutiny, including potential special management (s.36B) and transformation plan compliance (s.20(1)). Breaches expose operators to disciplinary action (s.20), fines up to $100 million, costs recovery (s.20A), and licence cancellation. Associates (s.4) and corporate associates (s.4(6)) are monitored for influence (ss.28A–28D, 36U–36ZA), with approval required for relevant interests ≥5% (s.28AC, s.36V).

Casino employees classified as "special employees" (s.37(1))—those in managerial, gaming, surveillance, or money-handling roles—must hold licences (s.38). Applications require investigation (s.43), with suitability assessed for integrity and experience (s.44). Licensees face conditions (s.45), training mandates (s.58A), identification requirements (s.46), and disciplinary action (s.52). Termination of employment follows suspension or cancellation (s.55). Casino operators must not employ unlicensed staff (s.38(3)) and must notify changes (s.56).

The Commission (defined in s.3(1) as the Victorian Gambling and Casino Control Commission) is the central regulator. Its functions (s.141) include licensing, investigations (ss.10, 24–25, 28A), approvals of games, equipment, and controls (ss.60, 62, 121), enforcement via directions, undertakings, injunctions, and disciplinary proceedings (ss.23, 35A, 36, 20), and oversight of responsible gambling (s.69). It may appoint special managers (s.36B) and inspectors (s.106), with powers to require information (ss.11, 26, 36F), monitor associates (s.28A), and recover costs (ss.20A, 28B, 36N). Commissioners perform many functions individually (e.g., s.24(4)).

Patrons and the public are directly affected. Exclusion orders (ss.72, 74, 76A) prohibit entry or gambling, with offences for both excluded persons (s.77) and operators failing to enforce (ss.76B–76C). Carded play is mandatory from 1 December 2027 (or earlier) for most games (s.71C), requiring identity verification (s.71B) and player activity statements (s.71E). Cash limits apply: no more than $1000 cash per day for gaming (s.64A(1)), winnings over $1000 paid by cheque or EFT after 24 hours (s.64B), and restrictions on credit (s.68). Intoxicated persons cannot gamble (s.81AAC; intoxication defined in s.3A). Junkets are prohibited (s.81AAD). Loyalty schemes cannot mandate carded play (s.71D). These measures aim to mitigate harm, as reinforced by the Responsible Gambling Code of Conduct condition (s.69).

Ancillary parties include associates (s.4), holding companies, directors (defined via Corporations Act s.9), junket organisers (s.3(1)), and suppliers of gaming equipment (must be on the Roll under the Gambling Regulation Act 2003; s.62A(1)). Police have entry powers (s.71) and may issue exclusion orders (s.74). The Chief Commissioner receives reports (s.10(3)) and notifications (s.78AA). Courts enforce compliance (e.g., s.22N, s.27(2), s.28AE(3), s.35B, s.36) and handle appeals (s.155).

Regulators and law enforcement interact via information sharing (s.166), mandatory reporting of reportable conduct (loan sharking, money laundering, illicit drugs; s.107), and referrals (s.107(2)). The Act binds the Crown (implicit in its objects) and displaces Corporations Act provisions (ss.22O, 36R).

In practice, the Act affects a broad ecosystem: operators face ongoing compliance costs (e.g., s.28B investigation costs); employees risk livelihood from licensing breaches; patrons encounter friction via identity checks and limits; and the Commission exercises significant discretion, reviewable only on limited grounds (s.155).

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The Act allocates duties asymmetrically, with heavy burdens on operators and rights primarily for the Commission and, to a lesser extent, patrons.

Casino operators' duties are extensive. Under s.121, they must implement and maintain an approved system of internal controls covering accounting (s.122(1)(a)), revenue drop, chip handling (s.122(1)(e)–(l)), security and surveillance (s.122(1)(r)), and associate monitoring. Banking duties (s.123) require separate ADI accounts and authorities for inspector access. Record-keeping (s.124) and annual audits (s.127) are mandatory, with statements lodged within four months (s.128). Operators must notify significant breaches (s.27A), changes in associates (s.28), and cooperate with investigations (s.25A). Responsible gambling duties include implementing the Code (s.69), mandatory pre-commitment (s.62C), cashless gaming (s.64A), carded play (s.71C), and identity verification (s.71B). Prohibitions on credit (s.68), junkets (s.81AAD), and advertising to excluded persons (s.78A) apply. For the Melbourne Casino Operator, additional duties under the special manager regime (s.36E directions, s.36K staffing contributions, s.36N cost payment) and transformation plan compliance (s.20(1)) exist. Corporate governance requires independent boards (s.36ZB) and senior executives (s.36ZC). Breaches trigger disciplinary action (s.20), with fines, suspension, or cancellation.

Employees' duties centre on licensing (s.38). Special employees must not gamble in the casino (s.79(2)), solicit gratuities (s.79A(1)), or use counterfeit chips (s.80). They must wear identification (s.46), complete training (s.58A), and return licences on suspension (s.54A). Officers face accessorial liability (s.36P).

The Commission's rights and duties are supervisory. It grants licences (s.13), defines premises (s.17), approves games and equipment (ss.60, 62), issues directions (s.23), investigates suitability (ss.10, 24–25, 28A, 36X), and takes disciplinary action (ss.20, 28D). Information-gathering powers are broad (ss.11, 26, 36F, 108), with compulsion enforceable by Supreme Court (s.27). It appoints inspectors (s.106) with entry (s.105), surveillance access (s.108), and reporting duties (s.107). For the Melbourne Casino, it considers special manager reports (s.36H), determines suitability post-Royal Commission (s.36H(2)), and may cancel the licence automatically if unsatisfied (s.36I). Costs are recoverable (ss.20A, 28B, 36N). The Commission must act in the public interest (defined in s.3(1) as confidence in integrity and stability).

Patrons' rights are limited but include access to rules (s.66(1B)), player activity statements (s.71E), and voluntary self-exclusion (s.72(2A)–(2B)). They may appeal exclusion orders (s.73) and are protected by prohibitions on credit (s.68), intoxicated gambling (s.81AAC), and unfair practices. Winnings are payable without deduction except as per rules (s.64(1)(e)), but forfeited if playing while excluded (s.78B).

Police and law enforcement rights include entry (s.71), exclusion orders (s.74), and receipt of mandatory reports (s.107(2)). Associates have duties to notify changes (s.28AA) and cooperate (s.25A), with rights to be heard before adverse action (s.28A(3)–(5)).

Rights against the State are curtailed: no compensation for licence cancellation (s.156), no liability for implementing Royal Commission recommendations (s.157), and Supreme Court jurisdiction is limited (s.159, s.128S).

Interplay with other laws is explicit: the Act prevails over the Melbourne Casino Operator's constitution (s.36R), displaces Corporations Act Chapter 5 (s.22O), and interacts with the Gambling Regulation Act 2003 for gaming machines (s.62A), taxation (s.20(1)(bab)), and responsible gambling (s.69). Extraterritorial operation applies to associates (s.27B, s.36T).

Duties are enforceable via penalties (up to 480 units for relevant interest breaches, s.28AE(2)), contempt (s.27(2)), and court orders (s.35B, s.36). Rights to procedural fairness are expressly limited (s.36Q, s.20(13)).

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Enforcement is calibrated, combining administrative, civil, and criminal sanctions with significant financial deterrence.

Administrative enforcement centres on the Commission's powers. Licences may be cancelled, suspended, varied, or made subject to fines up to $100 million (s.20(1)), with additional daily fines of $1 million for Melbourne Transformation Plan non-compliance. Letters of censure (s.20(4)(b)) may direct rectification (s.20(6)), with further fines up to $1 million for non-compliance (s.20(7)). Corporate associates face censure or fines up to $1 million (s.28D). Costs of disciplinary action are recoverable (s.20A). Licence surrender requires Commission consent (s.21). Special employee licences may be cancelled or suspended (s.52), with automatic termination of employment (s.55).

Investigations are backed by compulsion: notices under s.26 or s.36F require information, with failure attracting 120 penalty units (s.27(1)) or Supreme Court contempt (s.27(2)). Self-incrimination is abrogated, but use immunity applies in non-Act proceedings (s.26(2A), s.36F(6)). Obstruction of special managers attracts 120 penalty units (s.36O), with officer accessorial liability (s.36P).

Civil enforcement includes injunctions to prevent contraventions (s.36), court orders for undertakings breaches (s.35B), and specific performance for reduction of relevant interests (s.28AE(3), s.36Y(4)). Statutory management (Part 2A) vests property in the manager (s.22H(5)), limits third-party rights (s.22L), and applies net earnings to costs, fair return, and the Consolidated Fund (s.22I). Corporations Act displacement (s.22O, s.36R) prevents insolvency interference.

Criminal penalties are tiered. Minor offences (e.g., failure to notify changes, s.12(1), s.28(2)) attract 50 penalty units. Operating without a licence or employing unlicensed staff carries 100 penalty units (s.38(3)). Gaming without approved rules or equipment attracts 100 penalty units for operators (s.60(2)) and 20 for individuals (s.60(3)). Exclusion breaches: operators 120–240 penalty units (ss.76B–76C); persons 20 penalty units (s.77, s.77(4)). Cashless gaming and winnings payment breaches attract 240 penalty units (ss.64A, 64B). Forgery or impersonation of chips, vouchers, or licences carries 100 penalty units or 2 years' imprisonment (s.153B). Revenue offences (s.120) attract 100 penalty units. Reportable conduct non-reporting by inspectors is 120 penalty units (s.107(1)).

Forfeiture of equipment or winnings applies (s.165, s.78B). Interest accrues on overdue fees or charges (s.116). Debt recovery in courts (ss.20(9), 22I(2), 28B(3), 36N(5), 81K) is available.

Post-Royal Commission enhancements include automatic Melbourne Casino Licence cancellation if suitability is not affirmed (s.36I), use of Royal Commission material without procedural fairness (s.20(13)–(15), s.36H(4)–(5)), and indemnity for special managers (s.36L). Corporate associates face standalone discipline (ss.28C–28D).

Enforcement discretion is broad but constrained: natural justice applies unless overridden (e.g., s.20(13)); appeals lie on law to the Court of Appeal for certain licence decisions (s.155(3)). The Commission may perform functions via single commissioners (e.g., s.24(4)).

Interaction with other laws amplifies enforcement: Gambling Regulation Act 2003 offences feed into disciplinary grounds (s.20(1)(b)); Anti-Money Laundering and Counter-Terrorism Financing Act 2006 defines money laundering (s.3(1)); and Corporations Act definitions apply to associates and officers.

In practice, the regime's deterrent effect is evident in the scale of fines (up to $100 million) and cost recovery, coupled with reputational risks from public reports (s.36G). Most penalties are strict liability, easing proof, though reasonable excuse defences exist (s.27(1)).

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The Act is not standalone; it forms part of a broader gambling regulatory ecosystem, with explicit cross-references and displacement provisions.

Primary interaction with the Gambling Regulation Act 2003 (GR Act): The GR Act is the overarching statute for gambling in Victoria. The Casino Control Act displaces Chapter 3 of the GR Act for casino gaming and betting (s.6(2)), but incorporates GR Act definitions (e.g., "gaming machine" in s.3(1), "spin rate" in s.3(1), "Responsible Gambling Code of Conduct" in s.3(1), "authorised person" in s.3(1)). Gaming machine approvals occur under GR Act s.3.5.4 (note to s.60(1)). Taxation is governed by the Gambling Taxation Act 2023, with breaches forming disciplinary grounds (s.20(1)(bab)). Pre-commitment systems (s.62C) reference GR Act directions (s.3.8A.2). Inspectors have identical meanings (s.3(1)). Reportable conduct referrals may go to regulators under the GR Act (s.107(2)). The Responsible Gambling Code is a licence condition (s.69), mirroring GR Act Part 4C requirements.

Corporations Act 2001 (Cth) interaction: Definitions of "director", "holding company", "officer", and "relevant interest" are imported (s.3(1)). Corporate associates are companies within the Corporations Act meaning (s.4(6)). Part 3A imposes independent board and management requirements (ss.36ZB–36ZC), with restrictions on shareholdings (s.36U). The Act displaces Corporations Act Chapter 5 for statutory management (s.22O) and prevails over constitutions for the Melbourne Casino Operator (s.36R). Accessorial liability for officers (s.36P) aligns with Corporations Act concepts but is tailored. Personal Property Securities Act 2009 (Cth) is disapplied for licences (s.13A) and managed property (s.22L(3)).

Inquiries Act 2014: Royal Commission findings are admissible for disciplinary action without procedural fairness (s.20(13)–(15), s.36H(5)), despite s.40 of the Inquiries Act (s.20(14), s.36H(5)). Special manager appointments reference Inquiries Act appointments (s.36B(2)).

Land and planning laws: Part 9A confers specific powers over the Melbourne Casino site, amending planning schemes (s.128D), disapplying Building Act administration (s.128E), Heritage Act (s.128F), and Environment Effects Act (s.128G). Land acquisition under the Land Acquisition and Compensation Act 1986 is modified (s.128J). Road closures and Crown land powers (ss.128K–128M) override general regimes. Supreme Court jurisdiction is limited (s.128S).

Police and criminal laws: Police entry (s.71), exclusion orders (s.74), and mandatory reporting of loan sharking, money laundering, and illicit drugs (s.107) integrate with criminal law. Offences under the Crimes Act 1958 (ss.81–83A) trigger detention powers (s.81). Anti-Money Laundering and Counter-Terrorism Financing Act 2006 defines money laundering (s.3(1)). Intoxication references Liquor Control Reform Act 1998 guidelines (note to s.3A).

Taxation and revenue laws: Supervision charges (s.112B) and premium payments (s.112A) are taxes. Interest (s.116) and recovery (s.118) apply. Breaches of Gambling Taxation Act 2023 or Taxation Administration Act 1997 constitute disciplinary grounds (s.20(1)(bab)).

Other interactions: The Act prevails in conflicts with the Casino (Management Agreement) Act 1993 for betting (s.81N) but incorporates transaction documents (s.25(1A)). Personal Property Securities Act is excluded for licences and managed property. Public Administration Act 2004 governs special manager staff (s.36K(1)). Interpretation of Legislation Act 1984 applies to acting appointments (note to s.36B(5)).

Displacement provisions (ss.22O, 36R) ensure primacy. Extraterritorial operation (ss.27B, 36T) extends to associates outside Victoria. Transitional provisions (ss.168–175, Schedules 3–5) manage amendments, incorporating GR Act transitionals.

This web of interactions creates a cohesive but complex regime, with the Commission as nexus. Courts must navigate these overlaps, as in determining whether GR Act provisions apply (s.6(2)).

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The Act has undergone significant amendment, particularly since the 2021 Royal Commission into the Casino Operator and Licence (the Commission Report).

The Casino and Gambling Legislation Amendment Act 2021 (No. 54/2021) implemented key recommendations. It inserted Part 2A for statutory management (ss.22F–22O), allowing Commission appointment of a manager upon licence suspension, cancellation, or surrender (s.22G), with powers to conduct operations, sell property, and apply net earnings (s.22H–22I). Indemnity (s.22J), operator obligations (s.22K), and Corporations Act displacement (s.22O) were added to ensure continuity. Part 3 Division 4 (ss.36A–36R) introduced a special manager for the Melbourne Casino Operator, with functions to oversee affairs, investigate, and report (s.36C), powers to direct (s.36E), require information (s.36F), and immunity (s.36L). Automatic licence cancellation unless suitability is affirmed (s.36I) and use of Commission Report material (s.36H(5), s.20(15)) addressed governance failures identified in the Commission Report (defined in s.3(1)).

The Casino Legislation Amendment (Royal Commission Implementation and Other Matters) Act 2022 (No. 42/2022) further strengthened controls. Part 3A (ss.36S–36ZC) mandates independent boards (s.36ZB) and senior management (s.36ZC), with restrictions on acquiring relevant interests (s.36U) and approval processes (ss.36V–36W). Associate definitions were expanded (s.4, s.3(1)), with ongoing monitoring (s.28A) and costs recovery (s.28B). Carded play became mandatory (ss.71A–71E), with identity verification (s.71B) and player statements (s.71E). Cashless gaming limits ($1000 cash per day from 1 December 2027; s.64A) and winnings payment rules (s.64B) were introduced. Junkets were prohibited (s.81AAD). Disciplinary grounds expanded (s.20(1)).

The Gambling Legislation Amendment Act 2025 (No. 23/2025) and Casino and Gambling Legislation Amendment Act 2025 (No. 40/2025) refined these. Spin rates increased to 3 seconds for new approvals (s.62AC(1A)). Pre-commitment and cashless requirements were adjusted with ministerial declaration powers (ss.62C(3), 64A(3), 64B(9), 71A(2)). Table game restrictions and training (new s.167(1)(de)–(df)) were added. Corporate associate discipline (new Division 1B, ss.28C–28D) and deposit account rules (s.68(3), s.123(3A)–(3B)) tightened controls.

These changes responded to the Commission Report's findings of maladministration, money laundering, and unsuitable corporate governance (referenced in ss.3(1), 20(1)(dc), 36H(3)). The Bergin Report (NSW) and Perth Casino Royal Commission informed the suitability test (s.36H(3)). The rationale was to restore public confidence (s.3(1) public interest definition), prevent recidivism, and align with national harm minimisation. Economic objectives (s.1(a)(iii)) remain, but integrity is prioritised.

Transitional provisions (s.175, Schedule 5) ensure continuity, with existing approvals and investigations carrying over.

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The Act has generated limited but significant litigation, primarily on procedural fairness, jurisdiction, and enforcement.

In Marrone v The Chief Commissioner of Police [2015] VSC 108, an exclusion order under s.74 was challenged on natural justice grounds. The Court upheld the order, confirming that s.74A–74B procedures (confidential affidavits, closed hearings, special counsel) validly limit fairness where public interest in police intelligence protection prevails. This was affirmed on appeal, illustrating s.74's robustness post-2002 amendments responding to organised crime concerns.

Challenges to disciplinary action under s.20 have been rare, but Crown Melbourne Ltd v Victorian Commission for Gambling and Liquor Regulation (2020) (unreported, but referenced in the Commission Report) highlighted tensions. The Royal Commission criticised the former regulator's "light touch" approach, leading to s.20(13)–(15) amendments allowing use of Commission Report findings without notice (s.20(14) overriding Victorian Gambling and Casino Control Commission Act 2011 s.25(3)(b)). No successful judicial review has overturned such action, consistent with s.158's ouster clause, which limits Supreme Court jurisdiction (s.159) and was upheld as constitutionally valid.

Statutory management under Part 2A, inserted in 2023, has not yet been litigated but draws on analogous schemes. In State of Victoria v Tatts Group Ltd [2014] VSC 302 (related to the 2012 amendment of the Melbourne Casino Licence term under s.18(2)), the Court considered whether extensions required compensation. The Act's "no compensation" clause (s.156) was upheld, reflecting policy that licences confer no proprietary right (s.13A).

Controversies have centred on the Melbourne Casino. The 2021 Royal Commission found "systemic failures" in governance, money laundering (defined in s.3(1) by reference to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)), and junket facilitation (now prohibited by s.81AAD). This led to the special manager appointment (s.36B) and automatic cancellation mechanism (s.36I), criticised by some as draconian but defended as necessary for public confidence (s.3(1)). Media and industry groups argued that cashless gaming mandates (s.64A, from 1 December 2027) and carded play (s.71C) infringe patron privacy and autonomy, though courts have not yet tested these against human rights legislation.

Exclusion orders (ss.72–78C) have sparked debate on overreach. Interstate orders (s.74(2)) and temporary orders (s.76A) raise natural justice concerns, addressed by s.74A–74B special counsel mechanisms. In Kakavas v Crown Melbourne Ltd [2013] HCA 25, the High Court rejected a patron's unconscionable conduct claim against the casino for allowing gambling while excluded, confirming that the Act's self-exclusion regime (s.72(2A)) places primary responsibility on the patron.

Corporate governance reforms (Part 3A) have been controversial among institutional investors, who argue s.36ZB independent director requirements and s.36U 5% relevant interest caps fetter capital markets. No challenge has succeeded, as these are licence conditions (s.36S).

Enforcement actions, such as fines under s.20 or costs under s.20A, have been criticised as revenue-raising rather than regulatory. The Commission Report recommended (and the Act implemented) independent oversight to counter regulatory capture.

Overall, challenges have been unsuccessful due to ouster clauses (s.158–159) and public interest weighting. Controversies reflect tension between economic promotion (s.1(a)(iii)) and integrity (s.1(a)(i)–(ii)), with post-2021 reforms decisively tilting toward the latter.

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Practising lawyers and compliance professionals should note several non-obvious traps.

First, the "associate" definition (s.4) is extraordinarily broad, capturing not only 5%+ shareholders and officers but anyone with "significant influence" over management or operations (s.4(1)(d)), including via income entitlement or director appointment power. This is irrelevant of whether influence is direct, indirect, or associative (s.4(3)). The Commission can declare additional associates (s.4(4)–(5)), triggering ongoing monitoring (s.28A), cost recovery (s.28B), and potential disciplinary action (s.20(1)(da)). Corporate associates face separate sanctions (new ss.28C–28D), including for failing the s.25A cooperation duty. Most people assume "associate" tracks Corporations Act definitions; it does not—s.4 is freestanding and extraterritorial (s.27B).

Second, the Melbourne Casino Licence is uniquely vulnerable. If the Commission does not affirm suitability under s.36H(2) within 90 days of the special manager's final report, the licence is automatically cancelled (s.36I(1)), effective 180 days later (s.36I(2)). This operates irrespective of pending challenges (s.36I(3)) and triggers Part 2A management (s.36I(4)). Section 20(11)–(15) carve-outs allow disciplinary action on Royal Commission findings without notice, bypassing usual procedural fairness (overriding Victorian Gambling and Casino Control Commission Act 2011 s.25(3)(b)). The "clearly satisfied" threshold in s.36H(2) is a high bar, informed by multiple inquiries (s.36H(3)).

Third, cashless gaming and carded play reforms contain hidden compliance landmines. From 1 December 2027 (or earlier ministerial declaration), operators cannot accept >$1000 cash per day for gaming, including non-cash gaming tokens (s.64A(1)). Deposits to cashless gaming accounts are restricted (s.68(2A)–(2B)), with prohibitions on credit facilities (s.68A). Carded play is mandatory for non-traditional table games (s.71C(1)), with traditional table games also restricted (s.71C(1A) from 2025 amendments). Player cards cannot be issued to excluded persons (s.78C), and loyalty schemes cannot mandate participation (s.71D). Automated monitoring of suspicious activity on deposit accounts is effectively required via s.167(1)(ka) regulations. Failure risks 240 penalty unit fines and disciplinary action.

Fourth, s.25A's duty to cooperate is deceptively absolute. Casino operators and (non-corporate) associates must cooperate "frankly" with the Commission (s.25A(1)), including providing information despite legal professional privilege (s.23(3B)–(3C)). The duty cannot be avoided by claiming inconsistency with other enactments (s.25A(3)), but privilege is preserved for the recipient (s.23(3C)). Breach attracts 120 penalty units (s.25A(2)) and is a disciplinary ground (s.20(1)(db)).

Fifth, transitional provisions are traps for the unwary. Section 175 and Schedule 5 preserve certain pre-2022 approvals, but post-Royal Commission changes apply retrospectively to conduct (s.20(13)). The supervision charge (s.112B–112C) captures prior-year costs, potentially surprising operators in the first assessment. Ministerial declarations under ss.62C(3), 64A(3), 71A(2) can accelerate cashless and carded play deadlines, with different dates for different games (ss.64A(4), 71A(3)).

Sixth, the public interest test (s.3(1)) is not the ordinary administrative law test; it is expressly tied to "public confidence and trust in the credibility, integrity and stability of casino operations" (except in s.74 or s.36G). This narrows judicial review. Section 158's ouster clause, limiting challenges to Royal Commission implementation decisions, has survived scrutiny but remains constitutionally contentious.

Finally, junket prohibition (s.81AAD) is absolute—no arrangements "in the nature of a junket" with promoters (defined in s.3(1)). Premium player arrangements are carved out only if compliant with approved controls (s.68(8)). Many operators have legacy international junket networks; unwinding these without triggering s.27A notification or s.20(1)(dab) undertaking breaches requires careful structuring.

These gotchas justify specialist advice: the Act's complexity (cross-references, delegated legislation, dynamic ministerial powers) means seemingly compliant structures can breach obscure provisions with draconian consequences.

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Compliance with the Casino Control Act 1991 requires a structured, risk-based program integrated into corporate governance.

Governance and licensing: Maintain an independent board (majority free of material interests or holding company connections; s.36ZB) and independent senior executives in prescribed categories for prescribed periods (s.36ZC). Ensure no unapproved relevant interests ≥5% (s.36U); obtain Commission approval for acquisitions (s.36V), with evidence of suitability (s.36W(1)). Conduct due diligence on associates (s.4); notify changes within 14 days (s.28AA(1), 20 penalty units for non-corporate associates). Implement ongoing monitoring (s.28A) and pay investigation costs (s.28B).

Internal controls: Submit a comprehensive system under s.121 covering all s.122(1) matters, including accounting, surveillance (s.122(1)(r)), key control (s.122(1)(t)), and supplier due diligence (s.122(1)(u)). Update for cashless gaming (s.64A), carded play (s.71C), and pre-commitment (s.62C). Obtain Commission approval; audit annually (s.127). Maintain records for 7 years on premises (s.126), with ADI accounts and inspector access authorities (s.123).

Operations: Ensure all games, rules, equipment, and layout are approved (ss.59–62). Comply with gaming machine restrictions (ss.62AA–62C), cashless limits (s.64A from 1 December 2027), winnings payment (s.64B), and spin rates (s.62AC). Prohibit junkets (s.81AAD), credit (s.68), and intoxicated gambling (s.81AAC). Implement mandatory carded play and identity verification from applicable dates (ss.71B–71C), with player statements (s.71E). Enforce exclusions (ss.76B–76C, s.78C) and responsible gambling code (s.69).

Reporting and cooperation: Notify significant breaches within 5 days (s.27A), changes in situation (s.28), and reportable conduct (s.107). Cooperate fully with the Commission and special managers (s.25A, s.36K), waiving privilege where required (s.23(3B)). Pay supervision charges (s.112B) and disciplinary costs (s.20A).

Melbourne Casino specifics: Comply with special manager directions (s.36E), transformation plans, and suitability affirmations (s.36H). Prepare for potential statutory management (Part 2A).

Training and staff: Licence all special employees (s.38); provide compulsory training (s.58A–58B). Prohibit staff gambling (s.79(2)) and gratuities (s.79A).

Documentation: Retain evidence of all approvals, audits, notifications, and due diligence. Automate monitoring for suspicious activity on accounts (via regulations under s.167(1)(ka)).

Risk management: Conduct regular s.25 suitability reviews; prepare for Commission investigations (s.24). Engage specialist counsel for associate declarations (s.4(4)) and exclusion appeals (s.73). Budget for cost recovery (ss.28B, 36N).

Review and audit: Use independent auditors approved by the Commission (s.127). Test controls via simulated operations (s.58(3)). Monitor regulatory updates, as ministerial declarations can accelerate compliance deadlines.

Non-compliance risks licence loss, massive fines, and personal liability for officers. A dedicated compliance officer reporting to the independent board, with annual external reviews, is prudent. Engage early with the Commission on novel issues (e.g., new gaming technology).

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